Audit 360404

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-004 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Allowable Costs – Internal Control (Significant Deficiency) Criteria: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The internal control system will include reviews of expenses charged to federal awards to verify that the expenses charged are both allowable costs and allowable activities. These reviews should be documented by an approval noted on the supporting documentation for the specific expenditure. Context: During our audit, we sampled both payroll and non-payroll transactions from the country offices of the Organization. We noted that the Organization was unable to provide sufficient documentation to demonstrate that it had performed the required ongoing review and approval of expenses charged to the grant. The absence of such documentation indicates that the Organization did not fully comply with the federal requirements for internal controls over allowable costs and allowable activities. Condition: During our testing, we selected 40 payroll and 40 non-payroll transactions for testing. In our testing over payroll transactions, we noted that there were two (2) transactions in which the Organization was unable to provide evidence of a review and approval of the transaction. In our testing over non-payroll transactions, we noted that there was one (1) transaction in which the Organization was unable to provide evidence of a review and approval of the transaction. Cause and Effect: The Organization is not able at access supporting documentation due to political and social conditions in the countries where the Organization operates. Questioned Costs: None to report. Identified as a Repeat Finding: No. Recommendation: The Organization should ensure that headquarters staff have access to all supporting documentation for expenses charged to federal grants.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.

Finding 2024-005 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2023-2024 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2024, it was noted that the Organization did not comply with the FFATA subaward reporting requirements. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System (FSRS). Cause: The noncompliance was due to a lack of internal controls and procedures to ensure timely FFATA reporting. Staff responsible for grant reporting were unaware of the requirements. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Recommendation: We recommend that the Organization establish formal written policies and procedures to ensure compliance with FFATA reporting requirements. This should include training for responsible personnel, monitoring of subaward obligations, and a calendar or automated reminders to ensure timely reporting.